Does the NSF salary rule apply to all faculty members and staff charged to an NSF grant?
No. The NSF policy applies only to senior project personnel. The NSF Grants Policy Guide (GPG) defines senior personnel as:
- (co)Principal Investigator(s) - the individual(s) designated by the proposer, and approved by NSF, who will be responsible for the scientific or technical direction of the project.
- Faculty Associate (faculty member) - an individual other than the Principal Investigator(s) considered by the University to be a member of its faculty or who holds an appointment as a faculty member at another institution, and who will participate in the project being supported.”
Who does the NSF two-month salary policy NOT apply to?
The NSF two-month’ salary policy does not apply to:
- Post doctoral professionals
- “Soft-funded” employees (“research faculty”, research scientists, and similar individuals who are normally supported through sponsored-funding, i.e. their positions are not supported by permanent operating budget dollars)
- Research scientists not budgeted as senior personnel
- Other personnel not budgeted as senior personnel
Can NSF salary support be requested for summer and academic year effort?
As a general rule under the revised policy, salary for Senior Project Personnel is limited to two months and can be proposed for the summer and/or academic year. The University can continue to propose and charge summer salary only when suitable and the salary can be supported by the actual effort expended. If it is determined that it is more suitable to propose and charge academic year salary, it is up to the senior project personnel and his/her Department Head/Dean to determine how best to manage academic year salary savings.
Is funding in excess of 2 months’ salary allowable?
Yes, provided NSF approves it in advance. The two months is not a hard cap or ceiling. Institutions should propose salary for Senior Project Personnel in a manner that is suitable to the project. As the revised policy states: “any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award notice”
Does greater than two months salary for senior personnel budgeted on multiple NSF awards constitute as approval from NSF to charge greater than two months salary on NSF funds?
Yes, per informal NSF guidance, as long as the person months are listed in the approved budget that is attached to the NSF award notice, it constitutes NSF approval. No other approval is required.
How is the one year period determined?
The revised policy identifies the salary limit as applicable to “any one year”. RIT defines the one year period as the academic year beginning with the Fall quarter and ending with the Summer quarter.
For those situations where an individual (who is designated as Senior Project Personnel) has a single award and two-months of salary have been supported, managing the salary charges should be straight-forward. However, when the individual has: a) multiple active awards, b) possibly with overlapping budget periods, c) salary chargeable to both the summer and academic year, and d) the two-month salary limit is applicable to all of the awards, this will require careful monitoring to comply with this requirement. If you are in this situation, work closely with your Senior Research Administrators during the pre-award phase and your Sponsored Programs Accounting Representative in the post-award time frame.
Does the NSF two months salary policy apply to cost sharing commitments associated with NSF projects?
No, the policy does not apply to cost sharing commitments.
If senior project personnel plan to spend additional time working on the project, if it is funded, how should this be reflected in the proposal?
The budget should only show the salary being requested and the corresponding person months related to that salary for the senior personnel.
While the Current and Pending Support section may show the total person months projected to be spent working on the project by the senior personnel, the Facilities, Equipment and Other Resources section is what should be used to provide a narrative description of the resources available (both physical and personnel) to the project.
If a PI is being paid 100% from only NSF award(s) or NSF flow-through award(s) must they devote 100% effort to these awards and to no other activities?